Bank's Crypto Account Monitoring Update
From: XXXXX
Sent: Friday, December 22, 2023 11:17 AM
To: FDIC San Francisco Regional Office
Subject: FW: RADD Room
Importance: Low
a. Include email: Yes
b. Institution Name: XXXXX
c. City: XXXXX
d. State: XXXXX
e. Division: RMS
f. Folder: Correspondence
g. Source: RO
h. Doc Name: Miscellaneous
i. Description: XXXXX XXXXX
XXXXX
Federal Deposit Insurance Corporation
Case Manager
From: XXXXX
Sent: Friday, December 22, 2023 9:10 AM
To: XXXXX
Subject: FW: XXXXX - activity updated
Importance: Low
FYI: XXXXX So much for staying away from crypto related deposits.
From: XXXXX
Sent: Thursday, December 21, 2023 2:59 PM
To: Valderrama, Jaclyn M. XXXXX@FDIC.gov
Cc: XXXXX
Subject: XXXXX - activity updated
Importance: Low
This email is to inform you that an Activity Record in the XXXXX has been updated by XXXXX and needs to be reviewed by an RMS ARD.
Bank: XXXXX
Activity: Deposit Services
Sub-Activity (if applicable): Digital Asset Exchanges' Corporate and Settlement
Status: Live
FDIC Awareness: Notification per FIL-16-2022
Third Party (if applicable):
Activity Notes: On December 19, 2023, the bank notified the Region that they recently opened (date not provided) a new account for XXXXX for their business operations only. Bank management stated that the account is a business checking account with no interest rate. Bank management indicates they performed due diligence on the relationship, including a BSA and Compliance review. The bank also indicated that multiple management members had conversations with XXXXX and came to a comfort level that it XXXXX.
XXXXX
XXXXX The bank indicated that they made it clear to the XXXXX that the account would only be for their regular business operations, and we would not open any accounts for the purpose of loading and unloading the clients’ crypto wallets or any exchanges. The bank stated that they created the following guardrails on the relationship: * The BSA officer and the RM are to continue monitoring their account activity on an ongoing basis and alert Executive Management of any changes as agreed upon with the client. * Any found changes to the account balances above the initial: XXXXX and/or any balance fluctuation with an increase of: XXXXX above the opening account balance will require documented approval of the SVP, Director of Operations and Compliance, and a secondary approval of either the COO/CFO and/or the President and CEO in order to keep the increased funds in the account. (Documentation will be noted in the account notes in the Bank’s CRM system, Connections, and also in the HRA folder.) * Prior to the Bank allowing this client to have a larger relationship with the bank, defined as more than XXXXX, the Bank must present this request to the Board Executive Committee. Justification for this larger relationship decision should be included and documented." As of 12/21/23, the Region is working on a acknowledgement letter which will include a request list. The request list's goal will be to understand if the bank has appropriately confirmed that the funds being placed in the bank are actually corporate funds.
Assigned ARD Reviewer: VALDERRAMA, JACLYN (JVALDERRAMA)
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